`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`ee eeee xX
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`UNITED STATES OF AMERICA
`
`“We
`
`TONJA LEWIS,
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`:
`
`:
`
`CONSENT PRELIMINARY ORDER
`OF FORFEITURE/
`MONEY JUDGMENT
`
`Defendant.
`
`19 Cr. 789 (PGG)
`
`kee eee x
`
`WHEREAS, on or about November 6, 2019, TONJA LEWIS(the “Defendant”),
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`among others, was charged in three countsofa thirty-two count Indictment, 19 Cr. 789 (PGG) (the
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`“Indictment”), with conspiracy to violate the Travel Act, in violation of Title 18, United States
`
`Code, Section 371 (Count One); wrongful disclosure of individually identifiable healthcare
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`information, in violation of Title 42, United States Code, Sections 1320d-6(a)(1)-(3) and 1320d-
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`6(b)(3) and Title 18, United States Code, Section 2 (Count Nine); and solicitation of bribes and
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`gratuities by an agent of a federally funded organization, in violation of Title 18, United States
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`Code, Sections 666(a)(1)(B) and 2 (Count Twenty-Eight);
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`Case 1:19-cr-00789-PGG Document 655 Filed 12/21/21 Page 1 of 4
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`WHEREAS, the Indictment included, inter alia, a forfeiture allegation as to Count
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`Twenty-Eight of the Indictment, seeking forfeiture to the United States, pursuant to Title 18,
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`United States Code, Section 981(a)(1)(C), and Title 28, United States Code, Section 2461(c), of
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`any and all property, including but not limited to a sum of money in United States currency,
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`representing the proceeds traceable to the commission of the offense charged in count Twenty-
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`Fight of the Indictment that the Defendant personally obtained;
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`WHEREAS, on or about August 3, 2021, the Defendant pled guilty to Count
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`Twenty-Eight of the Indictment, pursuant to a plea agreement with the Government, wherein the
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`Defendant admitted the forfeiture allegation with respect to Count Twenty-Eight ofthe Indictment
`
`
`
`
`
`Case 1:19-cr-00789-PGG Document 655 Filed 12/21/21 Page 2 of 4
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`and agreed to forfeit to the United States, pursuant to Title 18, United States Code, Section
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`981 (a)(1)(C), and Title 28, United States Code, Section 2461 (c), a sum of money equal to no less
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`than $8,310 in United States currency, representing the amount of proceeds traceable to the
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`commission of the offense charged in Count Twenty-Eight of the Indictment, that the Defendant
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`personally obtained;
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`WHEREAS, the Defendant consents to the entry of a money judgment in the
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`amount of $8,310 in United States currency, representing the amount of proceeds traceable to the
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`offense charged in Count Twenty-Eight of the Indictment that the Defendant personally obtained;
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`and
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`WHEREAS, the Defendant admits that, as a result of acts and/or omissions of the
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`Defendant, the proceeds traceable to the offense charged in Count Twenty-Eight of the Indictment
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`that the Defendant personally obtained cannot be located upon the exercise of due diligence.
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`IT IS HEREBY STIPULATED AND AGREED,by and between the United States
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`of America, by its attorney Damian Williams, United States Attorney; Assistant United States
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`Attorneys, Mathew Andrews, Louis A. Pellegrino, and Stephanie Simon, of counsel; and the
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`Defendant, and her counsel, William Stampur, Esq., that:
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`Case 1:19-cr-00789-PGG Document 655 Filed 12/21/21 Page 2 of 4
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`1.
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`As aresult ofthe offense charged in Count Twenty-Eight ofthe Indictment,
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`to which the Defendant pled guilty, a money judgmentin the amount of $8,310 in United States
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`currency (the “Money Judgment”), representing the amount of proceeds traceable to the offense
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`charged in Count Twenty-Eight of the Indictment that the Defendant personally obtained, shall be
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`entered against the Defendant,
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`2.
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`Pursuant to Rule 32.2(b)(4) ofthe Federal Rules of Criminal Procedure,this
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`Consent Preliminary Order of Forfeiture/Money Judgmentis final as to the Defendant, TONJA
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`
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`Case 1:19-cr-00789-PGG Document 655 Filed 12/21/21 Page 3 of 4
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`LEWIS, and shall be deemed part of the sentence of the Defendant, and shall be included in the
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`judgment of conviction therewith.
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`3,
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`All payments on the outstanding money judgment shall be made by postal
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`moneyorder, bank or certified check, made payable, in this instance, to the United States Marshals
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`Service, and delivered by mail to the United States Attorney’s Office, Southern District of New
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`York, Attn: Money Laundering and Transnational Criminal Enterprises Unit, One St. Andrew’s
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`Piaza, New York, New York 10007 and shall indicate the Defendant’s name and case number.
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`4.
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`The United States Marshals Service is authorized to deposit the payments
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`on the Money Judgment in the Assets Forfeiture Fund, and the United States shall havecleartitle
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`to such forfeited property.
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`5.
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`Pursuant to Title 21, United States Code, Section 853(p), the United States
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`is authorized to seek forfeiture of substitute assets of the Defendant up to the uncollected amount
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`of the Money Judgment.
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`6.
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`Pursuant to Rule 32.2(b)(3) of the Federal Rules of Criminal Procedure, the
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`United States Attorney’s Office is authorized to conduct any discovery needed to identify, locate
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`or dispose of forfeitable property, including depositions, interrogatories, requests for production
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`Case 1:19-cr-00789-PGG Document 655 Filed 12/21/21 Page 3 of 4
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`of documents and the issuance of subpoenas.
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`7.
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`The Court shall retainjurisdiction to enforce this Consent Preliminary Order
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`of Forfeiture/Money Judgment, and to amendit as necessary, pursuant to Rule 32.2 of the Federal
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`Rules of Criminal Procedure.
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`[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]
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`
`
`
`
`
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`Case 1:19-cr-00789-PGG Document 655 Filed 12/21/21 Page 4 of 4
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`8.
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`The signature page of this Consent Preliminary Order of Forfeiture/Money
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`Judgment may be executed in one or more counterparts, each of which will be deemed an original
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`but all of which together will constitute one and the same instrument.
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`AGREED AND CONSENTED TO:
`
`DAMIAN WILLIAMS
`United States Attorney for the
`Southern District of New York
`
`MATHEW ANDREWS
`LOUIS A, PELLEGRINO
`STEPHANIE SIMON
`Assistant United States Attorney
`One St. Andrew’s Plaza
`New York, NY 10007
`(212) 637-6526 / 2617
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`By:
`
`By:
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`Case 1:19-cr-00789-PGG Document 655 Filed 12/21/21 Page 4 of 4
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` By: SLLIAMSTAMPUR,ESQ.
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`Attorneyfor Defendant
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`(Zl {21
`DATE
`
`(24\ol 21
`DATE
`
`(Zl{21
`DATE
`
`SO ORDERED:
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`fe..bo
`
`HONORABLE PAUL G. GARDEPHE
`UNITED STATES DISTRICT JODGE
`
`Dog [6 70%
`
`DATE
`
`,
`
`

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